No matter how focused you are on accurate environmental data management, mistakes can still happen. Maybe a decimal point got moved. Maybe the wrong emission factor was used in a calculation. Maybe someone simply misplaced an important document. Regardless, the end result is an inaccurate compliance report.
Whenever you discover you’ve made a mistake in your regulatory compliance reporting you are immediately faced with a very important choice: fix it immediately or hope no one notices.
Of course, there’s only one correct response to this dilemma.
Quite simply, it is always better to admit your mistakes and fix them as soon as possible.
That’s because the Environmental Protection Agency (and most other regulatory agencies) are generally forgiving of simple human errors. What’s most important to them is that you demonstrate your commitment to environmental compliance. This is also the reason why the EPA places such an emphasis on self-discipline and self-policing.
In contrast, ignoring inaccurate compliance reporting – even if you haven’t broken any of your legal obligations – sends a warning to the regulatory agencies that your primary concern isn’t accurate reporting. That’s when you’re most likely to get an EHS audit and a visit from an auditor who will be looking for every tiny little mistake that they can.
And they won’t just be looking at this year. No, they’ll most likely also dig back 5 years into your records and pick through those too. Catching errors and fixing them as soon as you notice them also helps prevent errors from getting archived and forgotten for years until an auditor digs them up later.
Mistakes Happen: Fix Them Quick
Here’s how to handle the situation if you discover a mistake on one of your reports:
- Use the wisdom of The 5 Whys to drill down to the root cause of the problem, so you can determine not only the source of the mistake within your own environmental management system, but the cause. Now is the time to deal with both and put the issue to bed once and for all. This could include improving your data management system, retraining an employee, or updating the formulas you’re using.
- Calculate the accurate information for your correct regulatory compliance report.
- Prepare a written explanation for why the error occurred. This should also include what actions were taken to correct the issue, as well as any precautionary actions that you took.
- Send the corrected report to your reporting agency, in the format used for the report (lately, the EPA has been moving all its compliance reporting to online etools).
The #1 Error-Proofing Method
Above all, however, prevention is always preferable. The most important step in regulatory compliance reporting is to review your results. Spotting errors can be easier than you’d expect if you have a proven accurate (or “clean”) data set that you can test your reports against.
In general, your production schedule is the number one indicator of where your environmental impacts and air emissions should stand.
When production goes up, you should see an increase in emissions. If you’ve slowed down production, you’ll likely have less to report.
So if you have one period of clean data to work with, you should be able to compare your production data between it and your sample report and discern if things look correct.
If the production hasn’t changed much, you should see similar reports. Any unexpected changes you see should raise a red flag and prompt further investigation.
Another tip for keeping your compliance data clean and accurate is to increase the frequency of your reviews. Many companies try to do one comprehensive internal data audit once a year (usually before a big report is due, like the Toxic Release Inventory report) in the hopes of spotting errors.
Usually, however, this just results in overworked environmental specialists who aren’t as alert to small data mistakes and who do not have enough time to get the job done right.
We recommend that you review all your major environmental impacts, like VOCs or hazardous waste, at least once a month.
Get started by scheduling a 30 minute meeting with everyone involved, even if that's just you. You probably won’t have time to review data daily, but checking your data monthly will still give you enough time to fix any errors and won’t be a burden on your time or resources.
Of course, if your environmental management system can automate a lot of these processes, you’ll find double checking your environmental data goes a lot faster.
Another reason to check data more frequently is so that you aren’t dealing with data years into the past. If your record keeping isn’t spotless, you might find it impossible to figure out what went wrong in your data a year or so farther back.
If you're dedicated to reviewing all the data you send out of your facilities, you probably won't have to deal with fixing any mistakes. But if some little error slips through, remember: taking responsibility and correcting your reports will keep you on the EPA's good side.
(Image credit: cogdog)
October 1, 2012